South Korea – Russia Tax Treaty
The South Korea-Russia tax treaty caps withholding on dividends at 10% for portfolio investors and 5% for qualifying direct investment, with interest payments fully exempt at 0%. Royalties are taxed at a uniform 5% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 48 active treaties in South Korea's network and one of 27 in Russia's. The general dividend rate of 10% compares to a median of 15% across South Korea's network and 10% across Russia's.
Verified data
FNS International Tax Treaties (nalog.gov.ru) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12). Note: treaties with US, UK, and CA suspended effective 2022-2023.)
Withholding Rate Summary
Source: Russia Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Russia) |
|---|---|---|
| Dividends (general) Portfolio investors | 10%saves 5% | 15% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 10% | 15% |
| Interest Bank interest, bonds, loans | 0%saves 20% | 20% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 5% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Russia)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 10% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 15%.
Source: Russia Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 0% withholding under this treaty, compared to the 20% statutory rate. Interest is fully exempt from source-country withholding under this treaty.
Source: Russia Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 5% to 5%.
Source: Russia Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Russia Treaty Reference
Comparative Context
🇰🇷South Korea's Network
Among South Korea's 48 active treaty partners, the 10% general dividend rate ranks 11th (median: 15%).
| Partner | Rate |
|---|---|
| Hungary | 10% |
| Poland | 10% |
| Romania | 10% |
| Russia (this treaty) | 10% |
| Saudi Arabia | 10% |
| Slovak Republic | 10% |
| Thailand | 10% |
🇷🇺Russia's Network
Among Russia's 27 active treaty partners, the 10% general dividend rate ranks 10th (median: 10%).
| Partner | Rate |
|---|---|
| Hungary | 10% |
| India | 10% |
| Italy | 10% |
| South Korea (this treaty) | 10% |
| Norway | 10% |
| Poland | 10% |
| Singapore | 10% |